Eligibility · 17 CFR § 4.7
Qualified Eligible Persons.
The firm's programs are offered exclusively to Qualified Eligible Persons as defined in CFTC Regulation 4.7. This page explains, in plain language, why eligibility is limited, who qualifies, and how qualification is verified.
Why eligibility is limited
A sophisticated-investor exemption.
Saratoga Capital Advisors offers its program under CFTC Regulation 4.7, an exemption that allows a registered commodity trading advisor to advise certain sophisticated investors without delivering a CFTC-reviewed disclosure document. In exchange, the program may be offered only to Qualified Eligible Persons — investors the regulation presumes able to evaluate the risks of a futures trading program on their own.
This is why no performance information appears on this website.
Program materials, including performance information, are furnished only after a prospective client’s QEP status has been verified.
Who qualifies · by status
Qualifying without a portfolio test.
Certain investors qualify by status alone, with no additional portfolio requirement. The principal categories:
Who qualifies · by portfolio
Accredited investors with a qualifying portfolio.
Most individual investors qualify through a second path: investors who meet the definition of accredited investor under Regulation D of the Securities Act — among other enumerated categories — and who also satisfy the regulation’s Portfolio Requirement by meeting any one of the following:
Securities portfolio
Ownership of securities and other investments with an aggregate market value of at least $4,000,000.
Margin on deposit
At least $400,000 in exchange-specified initial margin and option premiums, together with required minimum security deposits, on deposit for commodity interest transactions during the preceding six months.
Pro-rata combination
A proportional combination of the two — for example, half of the securities threshold together with half of the margin threshold.
Any one of the three satisfies the Portfolio Requirement.
Verification
How qualification works.
Request materials
A prospective client contacts the firm through the materials request form or by email.
QEP questionnaire
The firm provides a short questionnaire in which the prospective client identifies the basis of their qualification.
Materials furnished
Once QEP status is established, program materials — including performance information and the advisory agreement — are furnished directly.
This page is a plain-language summary provided for convenience. The text of CFTC Regulation 4.7 controls in all cases, and nothing on this page is legal advice. Prospective clients should consult their own advisers regarding qualification.
Believe you qualify as a QEP?
Request the program materials and the firm will respond with the qualification questionnaire and next steps.
Request materials